22INTHE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADO
Civil Action No. _____________________ LEACHMAN CATTLE OF COLORADO,LLC, a Colorado Limited LiabilityCorporation, and VERIFIED BEEF, LLC, aMontana Limited Liability Corporation,Plaintiffs,v.AMERICAN SIMMENTAL ASSOCIATION,a Montana Association, WADE R. SHAFER,individually, WILL TOWNSEND,individually,Defendants.
COMPLAINT AND REQUEST FOR PRELIMINARY INJUNCTION
Plaintiffs, Leachman Cattle of Colorado, LLC (“Leachman Cattle”) and Verified Beef,LLC (“Verified Beef”) (collectively “Plaintiffs”), file this Original Complaint and Request for Preliminary Injunction against Defendants American Simmental Association (“ASA”), Dr. WadeR. Shafer, individually, and Mr. Will Townsend, individually (collectively “Defendants”).
1. Plaintiff, Leachman Cattle of Colorado, LLC is a Colorado limited liabilitycompany with its principal place of business at 5100 ECR 70, Wellington, Colorado 80549.2. Plaintiff, Verified Beef, LLC is a Montana limited liability company with its principal place of business at 209 S. 19th Ave., Suite 3, Bozeman, Montana 59718.